Hello Kanchan

Guidelines are extremely well drafted and accept my heart felt congratulations 
for the same.
However, I offer following suggestions.

I would like to highlight following two provisions:

10.. Banks may consider variations in signature with some leniency and
should put in place their own verification system.

and
part 2

6. All procedures pertaining to the use of such cheque books by visually
impaired customers  must be in accordance with that of the other customers.

Visually impaired customers must be permitted to make any third-party checks
and banks should not fetter this service.

The aim of the provisions is surely progressive and convenient to us.
However, Cumulative effect of these two provisions is that dividing line 
between liniency in signature variations  and detecting forgery, for which 
banks are clearly responsible under law, is very thin and may put them in 
quandary and us--visually impaired---in needless trouble.

The better approach in my opinion, would be to adhere to CCPD guidelines in the 
matter, which imply that while issuing a cheque book, the bank official may 
obtain the signature of the visually impaired person on the cheques then and 
there and may attest such a signature so that problem of verification and 
variation in signature may not arise at the time of passing the cheque and 
forgery is also impossible as the forgerer would have to forge not only the 
signature but the attestation as well. The only risk in such a course is the 
theft of the cheque book the safe custody of which is clearly customer's 
responsibility as is that for proper use of debit and credit card. 
Unfortunately, this provision in CCPD guidelines has not been interpreted and 
applied as I have delineated above.

Such a course of signature/attestation may be resorted to unless and until we 
have proper biometric iddentification systems put in place.

Regards

Rajesh





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